Winter 2012 edition

Welcome to the winter edition of FSTP Perspectives. While the prior edition focused on regional market developments specific to the financial services sector, this edition is dedicated to a rapidly developing arena of transfer pricing, viz. intercompany pricing issues around financial transactions. This edition contains articles addressing:

Intercompany debt—US audit environment and considerations

The Netherlands: Landmark court case on the treatment of inter-company loans

Transfer pricing complexities related to cash pooling arrangements

A framework for evaluating related-party guarantees

Intra-group loans: Are loan terms and conditions important

Intra-group financial transactions documentation and risk

We hope you find these articles useful. If you have any questions or comments on these or related transfer pricing issues, please feel free to reach out to your regular PwC transfer pricing contact or a member of the editorial team.